Increased fines for violations in processing of personal data

Federal Law No. 589-FZ from 12.12.2023 "On Amending the Code of Administrative Offenses of the Russian Federation" has been adopted.

Starting from December 23, 2023, fines for processing personal data without the written consent of the subject of personal data or in violation of the requirements for its execution are increased.

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Preparation of a full package of documents on personal data protection, registration with Roskomnadzor


Large company. Business activities:

  • Wholesale of non-specialized food, beverages and tobacco products
  • Wholesale of industrial chemicals


Protection of personal data:

  • Development of a full package of documents on personal data from scratch
  • Registration of the company with Roskomnadzor taking into account the new requirements for cross-border transfer of personal data
  • Visit to the client and verification of proper storage of documents on personal data of both employees and counterparties. applicants
  • Checking the access system at the entrance to the back offices for compliance with 152-FZ

Work stages

  • Verification of all existing forms of personal data documents;
  • Visit to the client, verification of proper storage of personal data documents, including in case of non-automated processing of employees' personal data;
  • Negotiations with the client and choice of strategy in interaction with counterparties - individuals, sole proprietors for compliance with the norms of 152-FZ in terms of obtaining consents for processing of personal data;
  • Checking the pass system and internal regulations reflecting the system of issuing passes for the company's employees;
  • Development of a full package of documents taking into account the new forms of consent according to the latest amendments to the 152-FZ;
  • Registration of the company with Roskomnadzor as an operator for processing personal data, taking into account the specifics of cross-border transfer of personal data.

Audit of the organization's internal regulations on personal data for compliance with 152-FZ


Major international manufacturer of electrical and electronic equipment for motor vehicles, manufacturer of parts and accessories for motor vehicles. Activities:

  • carrying out maintenance and repair of passenger cars
  • trade in automobile parts, assemblies and accessories


Verification of internal regulations in the field of personal data taking into account the latest amendments and additions to the 152-FZ, indicating shortcomings, recommendations for elimination.

Project stages

  • carrying out a detailed review of local normative acts on personal data, as well as consent forms
  • analysis of violations and inconsistencies identified, taking into account all amendments to the 152-FZ
  • identification of missing forms, recommendations on their development
  • preparation of the final report on all identified shortcomings, amendments, description of the wording that reduces the risks of bringing the personal data processing Operator to liability, including to reduce the risks of Roskomnadzor inspection

Result – report on all identified violations and suggestions for corrections and additions.

Risks of acquisition and use of databases containing personal data of potential customers

It is not uncommon for entrepreneurs to consider using databases of potential customers in their commercial activities. There are many different offers on the market to buy and sell databases of personal data, but when buying them, it is worth considering the legislation on personal data and its application to the buyer of such data. Let us consider the main problems that a buyer of personal data bases may face.
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Placement of biometric personal data in the Unified Biometric System

In August 2023, MFCs (Public Service Centers) unexpectedly faced a rush of citizens' demand for the service of registration of refusal to collect biometric personal data. The reason is the rumors spreading that if you do not submit the appropriate application by 31.08.2023, biometric data of citizens will begin to collect uncontrolled by various organizations, primarily banks and telecom operators.
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Changes regarding personal data from March 1, 2023: new document forms, requirements of Roskomnadzor, and necessary actions for personal data operators

Until March 1, 2023, employers are required to submit special notifications to Roskomnadzor (hereinafter referred to as RKN) regarding the processing of personal data.
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Personal data, Transition to 1C:ZUP payroll & HR administration software, EDM & employee portal in 1C:ZUP 3

00:00 Start
02:00 General aspects and benefits of 1C:ZUP
05:00 Additional features and services: 1C: Employee Portal, Reporting, 1C: ITS, DirectBank
06:43 Advantages of 1C
11:14 Features and prerequisites for transitioning to 1C:ZUP 8.3:
+ Termination of support for ZUP 2.5 starting January 1, 2024
+ Withdrawal of foreign systems from the Russian market
12:40 Transition features to 1C ZUP 8.3. Complexity and duration factors. Stages
13:46 Data transfer methods: complete transfer and transfer of balances on a specific date
17:37 Experience of transitioning to 1C ZUP 8.3
22:10 HR EDMS functionality in 1C:ZUP 3 (Employee Portal)
24:39 Employee capabilities in 1C: Employee Portal, 1C:ZUP
25:50 Company capabilities
27:16 Electronic digital signature
28:29 Benefits of EDMS in 1C: Employee Portal
30:05 Personal data – main practices considering the changes in 2023
30:50 Processing personal data in 2023
33:37 Destruction of personal data
37:20 Assessment of the harm level in case of violation of the personal data protection law (152-FZ)
44:11 Features of transferring personal data abroad
48:05 Tightening of inspections by the Federal Service for Supervision of Communications, Information Technology and Mass Media (RKN) on the work of personal data operators
51:02 Documents that operators of personal data need to have in 2023
53:20 Experience with Softline cloud infrastructure
57:05 Question: Can you consolidate accounting from different versions of 1C and transfer it to 1C:ZUP 3?
58:08 Question: If ZUP is transferred to 1C:ZUP 3 and accounting is kept on version 2, can synchronization be ensured?
59:22 Question: Are there any limitations on customizing 1C? Companies need many reports for management.
1:00:20 Question: Can 1C Employee Portal only be used by employees who have 1C installed?
1:01:40 Can employees familiarize themselves with employment regulations through the 1C Employee Portal?
1:02:05 In which cases is consent for processing personal data not required during employment?
1:03:49 If a photo is used on the company’s website, is it considered biometric data?
1:05:04 If a photo is published on the company’s website, is consent required for the distribution of personal data?
1:05:34 Is consent required for processing personal data from visitors (e.g., business center)?
1:07:58 Do the requirements for processing personal data apply to individuals with whom the company has contractual relationships?


Date and time

31.05.2023 15:00-16:30


  • Russian




MS Teams


Reliability of the cloud infrastructure is provided by Softline:

  • Cloud infrastructure which fully complies with the requirements of 152 FZ, ISO/IEC 27001
  • Tier III data centers

Speakers and topics

Natalia Chernyakina

  • Team leader, business systems development group

Aspects of transitioning to 1C:ZUP 3 payroll & HR administration software

Download presentation PDF

Maria Brychkova

  • Payroll team leader

Functionality of electronic document management and employee portal in 1C:ZUP

  • Employee portal in 1C - capabilities for employees
  • Employee portal in 1C - capabilities for companies
  • Signing documents with an electronic signature
Download presentation PDF
Konsu - Анна Резникова

Anna Reznikova

  • Head of legal practice in Labor & Migration

Personal data: key practices and latest regulatory changes

  • Processing personal data in 2023
  • Destruction of personal data: new rules
  • Assessing the level of harm in case of personal data law violations: new procedure
  • Specifics of transferring personal data abroad in 2023
  • Increased inspections by Roskomnadzor for operators handling personal data
  • Documents that operators handling personal data need to have in 2023
Download presentation PDF

How register transborder data flows russia stepbystep en konsu o

How to Register Transborder Data Flows in Russia: A Step-by-Step Guide


Under what conditions is it allowed to transfer personal data abroad. Law No. 152-FZ "On Personal Data" divides all foreign countries into two categories.
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From march 2023 roskomnadzor will able ban data transfers en kon

From March 1, 2023 Roskomnadzor will be able to ban data transfers abroad for organizations and companies that process personal data

From March 1, 2023, new rules will come into force, whereunder Roskomnadzor will be able to ban cross-border personal data transfers by personal data processors (Government Decree No. 24 dated 16.01.2023).Read more

Roskomnadzor made official comments latest changes en konsu outs

Roskomnadzor made official comments on latest changes in regulation of personal data

From September 1, 2022, amendments to the law "On Personal Data" will come into force. At present, processors must notify Roskomnadzor (The Federal Service for Supervision of Communications, Information Technology, and Mass Media) about the start or continuation of any processing of personal data, except when the data is processed in order to protect the security of the state and public order, transport security, or if the processor processes the data exclusively without any automation equipment.

Currently, the updated form of the notice has not been approved; it will become available after approval by separate order of Roskomnadzor. Prior to that, PD processor can fill out a form approved by Order No. 94 dated 30.05.2017 on Roskomnadzor’s Personal Data Portal or can send this notice in hard copy to the local office of the agency at the processor’s place of registration.

After entry into force of Roskomnadzor’s order establishing a new notification form, the processor may send a notice of changes made to the information previously submitted to the Register of Data Processors Processing Personal Data.

No deadline for notifying Roskomnadzor about personal data processing has been determined. Thus, September 1, 2022 is not the deadline for submitting a notice on personal data processing.